Conflict of Interest Policy

FLCA Conflict of Interest Policy

May 2018

FLCA policy on conflicts of interest requires (a) those with a conflict (or who think they may have a conflict) to disclose the conflict/potential conflict, and (b) prohibit interested board members from voting on any matter in which there is a conflict.

• Pending the nature of the conflict of interest declaration, the Board Member will not vote on the matter at hand. If the conflict is of a broader nature affecting significant aspects of FLCA business, the Managing Directors may ask for the resignation of the Board Member..
• . Minutes of board meetings shall reflect when a board member discloses that s/he has a conflict of interests and how the conflict was managed, such as that there was a discussion on the matter without the board member in the room, and that a vote was taken but that the “interested” board member abstained (board members with a conflict are “interested”– board members without a conflict are “disinterested”)